Supreme Court of Alabama
Ex Parte Pamela R. Graham. (Re Pamela R. Graham v. Community Action Agency of North Central Alabama, Inc.).
July 25, 1997702 So. 2d 1215
Summary
The court held that the Agency's personnel manual was sufficiently specific to constitute an offer of a unilateral employment contract, which Graham could accept by continuing to work after becoming aware of its terms. The manual limited termination to just cause and established detailed disciplinary and grievance procedures, making summary judgment on Graham's breach-of-contract claims improper. The court affirmed the judgment on the unreviewed outrage claim, reversed it as to the contract claims, and remanded; Justice Maddox, dissenting, rejected the majority's reliance on the governing handbook-contract precedent.